I am a member and supporter…

I am a member and supporter of multiple conservation related organizations in Canada and Ontario and I have grave concerns about the proposed changes to the ESA. I will summarize my main concerns below.

1. Burying the proposed changes within a housing omnibus bill is disingenuous and disrespectful to the hundreds of thousands of Ontario citizens who support good conservation and environmental practices. It seems that the government's agenda (open for business) is driven in this case by land speculators, developers and the construction industry who have successfully lobbied the Progressive Conservative party in order to let them do an end run around scientific best practices for species conservation. Is Schedule 5 of Bill 108 the payback price the PC party is happy to pay to Ontario Proud and the businesses that were financial contributors to the party's election victory in 2017?

2. Ministerial discretion is being introduced or expanded in the proposed ESA. This strips away any pretext of scientific objectivity from the listing or protection of species which is currently based on best practices. Ministers are subject to interference and compromises in their duties, particular when officials in the Premier's office are calling the shots and micro-managing many aspects of the Ministry operations.

3. The fee-in-lieu fund in section 20 ("Pay to Pave") is a blatant get-out-of-jail card for industry to proceed with wholesale destruction of habitat in exchange for token financial penalty. I live in the eastern GTA (Durham Region), and have seen multiple housing developments in the area that cut and bulldoze first - they treat modest fines as a cost of doing business that they just pass on to the home buyers. The proposed fee-in-lieu fund is unnecessary, and instead real financial penalties should be enforced for violation of the ESA as it exists today (I understand they are rarely enforced currently, and when fines are levied they are inconsequential).

4. I do not believe the government's claims that the changes to the ESA buried in Bill 108 will have any significant impact on improving affordability or availability of housing stock in the province. This is simply a sneaky attempt to weaken protection of Ontario's current and future endangered species in order to reduce cost and inconvenience to the land speculation, development and building industries.